ML19327B668

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Forwards KA Doherty Affidavit Excluding Notarization to Substitute for Original Affidavit Submitted W/Intervenors 891018 Motion for Summary Disposition on Contentions JI-Onsite Ex-1 & JI-Onsite Ex-2
ML19327B668
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 10/25/1989
From: Brock M
MASSACHUSETTS, COMMONWEALTH OF
To:
NRC OFFICE OF THE SECRETARY (SECY)
References
CON-#489-9365 OL, NUDOCS 8911060091
Download: ML19327B668 (2)


Text

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\ b .THE COMMONWEALTH OF MASSACHUSETTS ,,33.; u r.

". DEPARTMENT OF THE ATTORNEY GENERAL

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JOHN W McCORMACK STATE OFFICE BUILOING oNE ASHBURToN PLACE. BOSTON 02108-1698 'gC) % N p 4.j() ,

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% J AMES M. SHANNON Of M hj

% anonscv cencnu . "[' ' ' .00Chiy1g i October 25, 1989 ,

Docketing and Service U.S. Nuclear Regulatory Commission '

Washington, DC 20555 E 'RE: In the Matter of Public Service Comnany of New [

Hamnshire et'al. (Seabrook Station Units l'and 2)

Docket No. 50-443/444- O b

Dear Sir / Madam:

Enclosed for filing please find the Affidavit of Kelly-Anne h Doherty, duly notarized. Please substitute this affidavit for that which was attached to Intervenors' Motion for Summcry Disposition on Contentions JI-Onsite Ex-1 and JI-Onsite Ex-2 which was filed on October 18, 1989. Except for' notarization, the enclosed affidavit is identical in form to that previously '

filed.

Thank you for your attention to this matter.

t very truly your ,

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L Matthew T. Brock l Assistant Attorney General L Nuclear Safety Unit Public Protection Bureau (617) 727-2200 l

Enclosure MTB/ tam 1

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8911060091 891025 PDR ADOCK 05000443 PDR s Q..

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AFFIDAVIT OF KELLY-ANNE DOHERTY  !

1. I, Kelly-Anne Doherty, having been duly sworn, do hereby depose and state that I am a paralegal with the Massachusetts Attorney General's Office in the Nuclear Safety Unit.
2. On July 31, 1989, this office requested the Scenario for the Seabrook Station Emergency Onsite Exercise

(" Scenario"), conducted on September 27, 1989, from the Nuclear Regulatory Commission ("NRC") through a Freedom of Information Act Request ("FOIA").

3. On October 10, 1989, Natalie Brown of the FOIA Branch of the NRC forwarded the Scenario to this office as requested.
4. The Scenario was attached as Exhibit 2 to Intervenors' Second Motion to Admit Contentions on the September 27, 1989 Emergency Plan Exercise filed on October 13, 1989.

Sworn to under the pains and penalties of perjury this 25th i day of October, 1989.

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KellymAnne Doherty J

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